Continuing Airworthiness rules

Report
From national to EU rules Continuing Airworthiness
Juan Anton
Continuing Airworthiness Manager
Rulemaking Directorate
EASA
30/31 January 2013
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What happened in the “old” times ?
 Before the existence of EU rules:
Every Member State had its own national aviation rules.
They covered all aviation aspects: operations, licensing,
maintenance, certification, airports, air navigation, etc.
This had the advantage of having all these aspects under
the control of the same Member State but it was certainly
difficult to move goods/services/licensed personnel
between different Member States.
Some Member States had their own bilateral agreements
and working arrangements with other states and
authorities.
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A first step into “standardisation”
 The first step into “standardisation” was the introduction of
JAA requirements:
They covered only certain aviation aspects and only for
certain aircraft categories and operations, such as:
 JAR-145
 JAR-66
 JAR-OPS1, JAR-OPS3
 JAR-FCL
The implementation was voluntary for each Member State
and could only happen if adopted in the national law.
Each Member State had the option to decide whether
they wanted to be standardised (through inspections) or
not.
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Introduction of EU rules
 The Basic Regulation EC1592/2002 (later replaced by
EC216/2008):
Created EASA.
Established EU requirements for airworthiness, which
were of mandatory compliance for all Member States
(superseded the national rules).
 As a consequence, Implementing Rules were created to
cover airworthiness, in particular:
Initial Airworthiness (EC1702/2003):
 Part-21 for Product Certification, certification of Design
and Production organisations, issuance of Certificates
of Airworthiness, etc.
 Certification Specifications (CSs) for product
certification
Continuing Airworthiness (EC2042/2003): Part-M/-145/66/-147.
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The Basic Regulation
 The European Parliament and the Council define the Scope
of Powers transferred to the Community.
 They adopt the Essential Requirements specifying the
objectives to be met.
Annex I : Essential Requirements for Airworthiness
Annex II : Excluded Aircraft
Basic Regulation
(EC) 216/2008
of
20 February 2008
Annex III: Essential Requirements for Pilot Licensing
Annex IV: Essential Requirements for Air Operations
Annex V: Qualified Entities
Annexes Va and Vb: Essential Requirements for
Aerodromes, ATM/ANS and Air Traffic Controllers
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The Implementing Rules
 The Commission adopts standards (Implementing Rules)
for implementing the essential requirements.
Regulation (EC) 1702/2003 on
Airworthiness and Environmental
Certification
Annex (Part 21)
Regulation (EC) 2042/2003
on Continuing Airworthiness
Annex I (Part-M): Continuing
Airworthiness Requirements
Annex II (Part-145): Maintenance
Organisation Approvals
Annex III (Part-66): Certifying Staff
Annex IV (Part-147): Training
Organisation Requirements
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The Implementing Rules
All Continuing Airworthiness Rules (Part-M, Part-145, Part-66,
Part-147) are divided in the following parts:
 Who is the Competent Authority (points M.1, 145.1, 66.1
and 147.1).
 Section A: Technical Requirements.
 Section B: Procedures for Competent Authorities.
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Soft Laws of EASA
 EASA adopts non binding standards for implementing the
essential requirements.
AMC &
Guidance
Material
Certification
Specifications
AMC &
Guidance
Material
AMC 20
Part 21
CS 25
CS 34
CS 36
CS E
CS P
CS APU
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CS AWO
CS ETSO
CS Definitions
CS 22
CS 23
CS 27
CS 29
CS VLA
CS VLR
Parts M, 145,
66, 147
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Continuing Airworthiness rules
 How the new Implementing Rules for Continuing
Airworthiness were created:
Part-145/-66/-147 were relatively easy: They were based
on similar JAA rules already existing, with the main
difference of introducing “Authority Requirements” in
Section B of each rule.
What about Part-M?
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Why Part-M was necessary?
 Part-M was necessary because the Basic Regulation
EC1592/2002, under the Continuing Airworthiness
requirements, covered a much larger range of activities,
operations and aircraft categories than the existing JAA
rules. As a matter of fact:
 Part-145 only covered the requirements for the
approval of a maintenance organisation and how this
organisation performs the maintenance they have
been ordered by the owner/operator/CAMO.
 However, Part-145 did not cover how the
airworthiness status of the aircraft is determined,
controlled and maintained, how maintenance is
planned and ordered and who is responsible for what.
 The use of a Part-145 organisation was only required
for large aircraft and aircraft used in Commercial Air
Transport. It was too restrictive for non large aircraft
and other types of operations.
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What is included in Part-M ?
 How the airworthiness status of the aircraft is determined,
controlled and maintained, how maintenance is planned and
ordered and who is responsible for what. (Subpart-M of JAR-OPS1
was used as a basis and it was adapted to the different aircraft
categories and operations)
 Maintenance standards to be met.
 Requirements for maintenance organisations involved in the
maintenance of aircraft other than large not used for Commercial
Air Transport (Subpart F maintenance organisations). For large
aircraft and aircraft involved in CAT, the requirements are in Part145.
 Requirements for independent certifying staff performing certain
maintenance for aircraft other than large not used for Commercial
Air Transport.
 Pilot-owner maintenance.
 Requirements for the renewal of the validity of the Certificate of
Airworthiness (airworthiness reviews).
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Responsibilities
Main responsibilities of the owner/operator/CAMO:
 The owner/operator/CAMO is responsible for the
airworthiness of the aircraft and deciding what
maintenance is needed and when and where it has to be
performed.
 The owner/operator/CAMO is responsible for coordinating
maintenance activities when several maintenance
organisations are involved.
 The owner/operator/CAMO is not responsible for how the
maintenance is performed. This is the responsibility of the
maintenance organisation (it holds an approval).
 However, the owner/operator/CAMO is responsible for
verifying that all the maintenance ordered has been
completed and released, as well as for maintaining the
corresponding records.
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Fundamental aspects of the system
Fundamental aspects of the system:
The system is based on a chain of different approvals:
 CAMO (Part-M, Subpart G), Maintenance Organisation
(Part-145 or Part-M Subpart-F), Licensed personnel (Part66), Maintenance Training Organisations (Part-147).
 Each approval is under the oversight of a competent
authority.
 Adequate communication and exchange of information
between competent authorities is essential since there are
different authorities involved:
 State of Registry, State of Operator, State of CAMO,
State of the Maintenance Organisation, State issuing
the Part-66 licence.
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Fundamental aspects of the system
Fundamental aspects of the system:
The system is based on a chain of oversight activities
and responsibilities:
 The Quality System of the approved organisation.
 The oversight performed by the competent authority
issuing the organisation approval.
 The oversight performed by the State where the
organisation is located (may be different from the
State who issued the approval).
 Airworthiness Reviews performed on the aircraft for
the renewal of the Certificate of Airworthiness.
 The ACAM (Aircraft Continuing Airworthiness
Monitoring) programme of the State of Registry.
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